Dr. Thompson is a neurologist who provides care in Mainstreet, Indiana. She owns her own practice, but costs to maintain her MRI requirements are increasing. She is considering using space at St. Vincent Hospital and sending patients that require MRI or other imaging procedures to St. Vincent Radiology Department. Her longtime friend, whom she met in medical school, is the CEO of St. Vincent's and told her she could use the space for free for a while until her practice recovers.

Do you think Dr. Thompson has violated the Stark Law? Why?

How would you fix this?

How would you modify the agreement?

Does the agreement comply with the Stark Law?

If so, under what exception? What if the only evidence of an agreement was Dr. Thompson and the CEO's handshake?